Standard Interpretations - Table of Contents
• Standard Number: 1910.146

July 13, 1994

Kenneth A. Krukonis
Technical Manager
Fox River Paper Company
Rising Paper Division
Housatonic, Massachusetts 01236

Dear Mr. Krukonis:

This is in response to your letter of August 31, which you wrote to Mr. Ronald E. Morin of the Occupational Safety and Health Administration's (OSHA) Springfield Area Office, requesting an interpretation of the "order of testing" requirement in 29 CFR 1910.146(d)(5)(ii) and 29 CFR 1910.146(d)(5)(iii). Your letter has been forwarded to this Office for reply. Please accept our apology for the delay in this response.

You state in your letter that your permit spaces do not contain flammable gas and yet you are sampling for hydrogen sulfide which is flammable between the range of 4.3% to 46% concentration. Where there is no potential for a flammable atmosphere hazard, you are correct in proceeding to monitor for potential toxic air contaminants. If hydrogen sulfide is the only toxic potentially present in the permit spaces, OSHA will consider the proper use of the MSA #361 analyzer to comply with 29 CFR 1910.146(c)(5)(ii)(C) and 29 CFR 1910.146(d)(5)(iii).

In addition, given the automatic sampling program feature of the instrument described in your letter, OSHA believes that deviation from the sequence of testing mandated by the referenced standards will not have significant impact on employee safety and health at the Rising Paper Division of the Fox River Paper Company. The rapidity of readout of your instrument and the fact that it continuously cycles (every 5 seconds) obviates the fixed sequence of testing called for in the standard. Prudent practice dictates that specific values of each substance being recorded would be the average of several cycles.

We hope this information will be helpful. Please feel free to contact u